PRIVACY STATEMENT

Your personal information protection rights include knowing why your personal information is collected, how it is used, and to whom it is disclosed. 

Access Rights 

• PHIPA provides a broad right of access to the personal health information held by a custodian about an individual. However, PHIPA provides some grounds for refusing such a request including the following:  

• it is quality of care information or information generated for the College’s quality assurance program;  

• it is raw data from standardized psychological tests or assessments;  

• there is a risk of serious harm to the treatment or recovery of the individual or of serious bodily harm to another person; or  

• access would reveal the identity of a confidential source.  

PHIPA provides procedures for handling access requests including the following: 
 

• the custodian must assist the individual in making a meaningful request, if necessary;  

• while the custodian can informally provide access, it can also insist upon a formal written request;  

• the custodian should, where reasonably practical, explain terms, codes and abbreviations;  

• the custodian must notify the individual of his or her right to complain to the Information and Privacy Commissioner of Ontario if the request for access is refused (along with the reasons for the refusal) and the burden of justifying the refusal is on the custodian;  

• the custodian can refuse frivolous, vexatious and bad-faith requests for access;  

• the custodian must satisfy themself of the identity of the individual before granting him or her access;  

• the custodian must provide any personal health information maintained in electronic format to the individual in a specified electronic format to facilitate portability of the information for the individual;  

• the custodian can only charge a reasonable cost recovery fee for access and must provide an estimate of the fee in advance (the Information and Privacy Commissioner has held that a reasonable fee is $30.00 for the first 20 pages and 25 cents for every additional page); and 

• the custodian must respond to a request for access as soon as possible and no later than 30 days after receiving the request, but the custodian can extend the time for a response by another 30 days if necessary.  

 

Correction Rights  

• We have an obligation to correct personal health information if it is inaccurate or incomplete for the purposes it is to be used or disclosed. 

• Clients may request that their health information be corrected if it is inaccurate or incomplete. Such requests must be made in writing and must explain what information is to be corrected and why.  

• We must respond to requests for correction within 30 days (or seek an extension of up to an additional 30 days but only if we have let the client know, in writing). Corrections are made in the following ways: 

  • Striking out the incorrect information in a manner that does not obliterate the record or 

  • If striking out is not possible:  Labelling the information as incorrect, severing it from the record, and storing it separately with a link to the record that enables Glebe Psychotherapy or the Health Information Custodians to trace the incorrect information, or 

  • Ensuring there is a practical system to inform anyone who sees the record or receives a copy that the information is incorrect and directing that person to the correct information. 

 

• The record will not be corrected if: 

  • The record was not originally created by the Health Information Custodians and the Health Information Custodians do not have the knowledge, expertise or authority to correct the record, or 

  • The record consists of a professional opinion which was made in good faith. 

 

• If we choose not to correct a record, the client must be informed in writing. The client will have the choice to submit a statement of disagreement, which will be scanned onto the health record and released any time the information that was asked to be corrected is released. In these cases, clients have a right to complain to the Information and Privacy Commissioner of Ontario. 

Complaints 

• We will receive and respond to complaints or inquiries about our policies and practices relating to the handling of personal health information. We will inform clients who make inquiries or lodge complaints of other available complaint procedures.  

• All complaints about the nature of the safeguards or the secure handling of information related to Glebe Psychotherapy’s information records, both electronic and physical, should be directed to the Information Security Custodian contact person - Susan Kim (819) 712-8405. 

• A review will be conducted within 7 business days.

• If a complaint is found to be justified, we will take appropriate measures to respond.  

• The custodian will address any further action required regarding the complaint, via internal procedures, or if required via the Privacy Commissioner of Ontario.

• The Information and Privacy Commissioner of Ontario oversees compliance with privacy rules and PHIPA. Any individual can make an inquiry or complaint directly to the Information and Privacy Commissioner of Ontario by writing to or calling: 

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         2 Bloor Street East, Suite 1400  

         Toronto, Ontario M4W 1A8 Canada 
         Phone: 1 (800) 387-0073 (or (416) 326-3333 in Toronto) 
         Fax: 416-325-9195 
         www.ipc.on.ca